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Chain of Custody
1 G.R. No. 205639 January 18, 2016
PEOPLE OF THE PHILIPPINES, Appellee,
vs.
ANITA MIRANDA y BELTRAN, Appellant

FACTS:

It was confirmed that ANITA MIRANDA was engaged in the illegal sale of shabu after a surveillance was conducted outside her house. Thus, a
buy-bust team was formed. PO2 Rodil, who acted as the poseur-buyer went to Anita’s house and told her that she was buying shabu worth
P400. Anita then went inside her house and upon her return, handed to PO2 Rodil one (1) transparent plastic sachet containing white
crystalline substance. After PO2 Rodil gave Anita the marked money as payment, she then made a missed call to PO2 Chan as a pre-arranged
signal. SPO1 Buhay and PO2 Chan then arrested Anita. PO2 Chan got the marked money, while PO2 Rodil held on to the plastic sachet
containing white crystalline substance. The team then informed Brgy. Ibaba West Councilo Arnel Almazan about the operation and they all
brought Anita to the Calapan Police Station.

Inventory of the seized item and the taking of Anita's photos were made at the police station. PO2 Rodil marked the seized item and submitted
the same for laboratory examination on the same day. The Forensic Chemist, Police Inspector Alviar confirmed the specimen submitted
positive for methamphetamine hydrochloride (shabu).

Anita was then charged before the RTC with violation of Section 5, Article II of Republic Act (R.A.) No. 9165, otherwise known as
the Comprehensive Dangerous Drugs Act of 2002.

Both the RTC and CA found Anita guilty beyond reasonable doubt of the crime charged.

ISSUE:

W/N the chain of custody requirement was complied.

RULING:

Yes. Chain of Custody means the duly recorded authorized movements and custody of seized drugs or controlled chemicals or plant sources of
dangerous drugs or laboratory equipment of each stage, from the time of seizure/confiscation to receipt in the forensic laboratory to
safekeeping to presentation in court for destruction. Such record of movements and custody of seized item shall include the identity and
signature of the person who held temporary custody of the seized item, the date and time when such transfer of custody were made in the
course of safekeeping and use in court as evidence, and the final disposition.

In this case, the Court finds that the prosecution was able to establish the crucial links in the chain of custody of the seized sachet of shabu.
There is no doubt that the sachet of shabu, which was bought and confiscated from Anita, brought to the police station, and was submitted to
the crime laboratory for a qualitative examination, was the very same shabu presented and identified in court. The police had sufficiently
preserved the integrity and evidentiary value of the seized item, thus, complying with the prescribed procedure in the custody and control of
the confiscated drugs.